Audit 353078

FINDING - Noncompliance with Enrollment Reporting Requirements Federal Agency: Department of Education Assistance Listing Numbers: 84.268, 84.063 Program Names and Award Numbers: Federal Direct Student Loans, Federal Pell Grant Program Program Expenditures: $10,983,995, $12,186,160 Questioned Costs: None Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure that the effective date of students who unofficially withdrew was accurately reported to National Student Loan Data System (NSLDS). CONDITIONS FOUND & CRITERIA During our testing of the University’s compliance with enrollment reporting requirements for Direct loan programs via the NSLDS (OMB No. 1845-0035), we noted the University did not update program-level and campus-level effective enrollment dates for the students’ appropriate withdrawal date. We noted the following: - Two of 25 (8%) of the students originally tested withdrew during the Fall semester however were reported to NSLDS as withdrawn with an effective enrollment change date for the last day of the spring semester. NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) - Five of 25 (20%) of the students originally tested withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively. - 15 of 15 (100%) additional students tested as a result of the error withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively thus bringing total errors to 22 of 40 students (55%). NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) and can be retroactively reported to reflect the accurate effective date (See 4.4.5 of NSLDS Enrollment Reporting Guide) The sample was not intended to be, and was not, a statistically valid sample. NSLDS Enrollment Reporting Guide (4.4.5) does speak to continue education as a way of determination of student’s enrollment status. However, this is only applicable when evaluating the end of the current school year, during the spring and summer semester, with respect to the upcoming school year’s fall semester. CAUSE University’s officials stated these students’ enrollment effective date was not reported until the last day of the semester by confirming if the student was enrolled in the next term, which resulted in reporting the incorrect date. EFFECT Failure to meet enrollment reporting requirements is noncompliance with federal regulations and could result in loss of loan/grant funding in future years. (Finding Code No. 2024-006) RECOMMENDATION We recommend the University’s registrar’s office implement processes and controls to ensure the appropriate determination of the last date of attendance for withdrawal determinations are reported to NSLDS. UNIVERSITY RESPONSE The University agrees with the recommendation.

FINDING - Noncompliance with Enrollment Reporting Requirements Federal Agency: Department of Education Assistance Listing Numbers: 84.268, 84.063 Program Names and Award Numbers: Federal Direct Student Loans, Federal Pell Grant Program Program Expenditures: $10,983,995, $12,186,160 Questioned Costs: None Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure that the effective date of students who unofficially withdrew was accurately reported to National Student Loan Data System (NSLDS). CONDITIONS FOUND & CRITERIA During our testing of the University’s compliance with enrollment reporting requirements for Direct loan programs via the NSLDS (OMB No. 1845-0035), we noted the University did not update program-level and campus-level effective enrollment dates for the students’ appropriate withdrawal date. We noted the following: - Two of 25 (8%) of the students originally tested withdrew during the Fall semester however were reported to NSLDS as withdrawn with an effective enrollment change date for the last day of the spring semester. NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) - Five of 25 (20%) of the students originally tested withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively. - 15 of 15 (100%) additional students tested as a result of the error withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively thus bringing total errors to 22 of 40 students (55%). NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) and can be retroactively reported to reflect the accurate effective date (See 4.4.5 of NSLDS Enrollment Reporting Guide) The sample was not intended to be, and was not, a statistically valid sample. NSLDS Enrollment Reporting Guide (4.4.5) does speak to continue education as a way of determination of student’s enrollment status. However, this is only applicable when evaluating the end of the current school year, during the spring and summer semester, with respect to the upcoming school year’s fall semester. CAUSE University’s officials stated these students’ enrollment effective date was not reported until the last day of the semester by confirming if the student was enrolled in the next term, which resulted in reporting the incorrect date. EFFECT Failure to meet enrollment reporting requirements is noncompliance with federal regulations and could result in loss of loan/grant funding in future years. (Finding Code No. 2024-006) RECOMMENDATION We recommend the University’s registrar’s office implement processes and controls to ensure the appropriate determination of the last date of attendance for withdrawal determinations are reported to NSLDS. UNIVERSITY RESPONSE The University agrees with the recommendation.

FINDING - Noncompliance with Grant Report Requirements Federal Agency: Department of Education Assistance Listing Numbers: 84.425F Program Names and Award Numbers: Education Stabilization Fund Under the Coronavirus Aid, Relief, And Economic Security Act [COVID-19 Higher Education Emergency Relief Fund: Institution Portion (P425F200852)] Program Expenditures: $2,160,298 Questioned Costs: None Northeastern Illinois University (University) did not have adequate procedures in place to ensure the Education Stabilization Fund - Higher Education Emergency Relief Fund (HEERF) reports were accurate and timely submitted to the U.S. Department of Education and posted to the University’s website. CONDITIONS FOUND & CRITERIA During our testing of the University’s compliance with the grant reporting requirements for HEERF, we noted the University did not review the required reports to ensure accuracy and compliance with the reporting requirements of the grant agreement. We noted the following: - Four of 4 (100%) Quarterly Public Reports improperly did not report the cumulative student aid disbursed for each undergraduate and graduate student. The Department of Education Quarterly Budget and Expenditure Reporting Form requires the posting of cumulative student aid disbursed by quarter for both undergraduate and graduate. - Two of 4 (50%) Quarterly Public Reports were posted 175 days and 84 days late to the University’s website. The Department of Education Quarterly Budget and Expenditure Reporting Form requires the University to post the Quarterly Public Reports covering each quarterly reporting period (September 30, December 31, March 31, June 30), no later than 10 days after the end of each calendar quarter. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards to establish and maintain effective internal control designed to reasonably ensure compliance with Federal laws, statutes, regulations, and the terms and conditions of the Federal award. CAUSE University officials stated required reports were not timely and accurately submitted due to turnover within the University resulting in staffing constraint. EFFECT Failure to meet grant reporting requirements is noncompliance with federal regulations and could result in loss of grant funding in future years. (Finding Code No. 2024-007, 2023-007, 2022-005, 2021-008, 2020-011) RECOMMENDATION We recommend the University improve its grant reporting and monitoring process to adhere with grant requests for reporting utilizing a calendar schedule and proper review before submission. UNIVERSITY RESPONSE The University agrees with the recommendation.

FINDING - Noncompliance with Enrollment Reporting Requirements Federal Agency: Department of Education Assistance Listing Numbers: 84.268, 84.063 Program Names and Award Numbers: Federal Direct Student Loans, Federal Pell Grant Program Program Expenditures: $10,983,995, $12,186,160 Questioned Costs: None Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure that the effective date of students who unofficially withdrew was accurately reported to National Student Loan Data System (NSLDS). CONDITIONS FOUND & CRITERIA During our testing of the University’s compliance with enrollment reporting requirements for Direct loan programs via the NSLDS (OMB No. 1845-0035), we noted the University did not update program-level and campus-level effective enrollment dates for the students’ appropriate withdrawal date. We noted the following: - Two of 25 (8%) of the students originally tested withdrew during the Fall semester however were reported to NSLDS as withdrawn with an effective enrollment change date for the last day of the spring semester. NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) - Five of 25 (20%) of the students originally tested withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively. - 15 of 15 (100%) additional students tested as a result of the error withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively thus bringing total errors to 22 of 40 students (55%). NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) and can be retroactively reported to reflect the accurate effective date (See 4.4.5 of NSLDS Enrollment Reporting Guide) The sample was not intended to be, and was not, a statistically valid sample. NSLDS Enrollment Reporting Guide (4.4.5) does speak to continue education as a way of determination of student’s enrollment status. However, this is only applicable when evaluating the end of the current school year, during the spring and summer semester, with respect to the upcoming school year’s fall semester. CAUSE University’s officials stated these students’ enrollment effective date was not reported until the last day of the semester by confirming if the student was enrolled in the next term, which resulted in reporting the incorrect date. EFFECT Failure to meet enrollment reporting requirements is noncompliance with federal regulations and could result in loss of loan/grant funding in future years. (Finding Code No. 2024-006) RECOMMENDATION We recommend the University’s registrar’s office implement processes and controls to ensure the appropriate determination of the last date of attendance for withdrawal determinations are reported to NSLDS. UNIVERSITY RESPONSE The University agrees with the recommendation.

FINDING - Noncompliance with Enrollment Reporting Requirements Federal Agency: Department of Education Assistance Listing Numbers: 84.268, 84.063 Program Names and Award Numbers: Federal Direct Student Loans, Federal Pell Grant Program Program Expenditures: $10,983,995, $12,186,160 Questioned Costs: None Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure that the effective date of students who unofficially withdrew was accurately reported to National Student Loan Data System (NSLDS). CONDITIONS FOUND & CRITERIA During our testing of the University’s compliance with enrollment reporting requirements for Direct loan programs via the NSLDS (OMB No. 1845-0035), we noted the University did not update program-level and campus-level effective enrollment dates for the students’ appropriate withdrawal date. We noted the following: - Two of 25 (8%) of the students originally tested withdrew during the Fall semester however were reported to NSLDS as withdrawn with an effective enrollment change date for the last day of the spring semester. NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) - Five of 25 (20%) of the students originally tested withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively. - 15 of 15 (100%) additional students tested as a result of the error withdrew during their respective fall and spring semester however were reported to NSLDS as withdrawn with an effective enrollment at the end of the semester and not updated retroactively thus bringing total errors to 22 of 40 students (55%). NSLDS requires the that date the current enrollment status is to be reported when the change was first effective (See 4.4.2 of NSLDS Enrollment Reporting Guide) and can be retroactively reported to reflect the accurate effective date (See 4.4.5 of NSLDS Enrollment Reporting Guide) The sample was not intended to be, and was not, a statistically valid sample. NSLDS Enrollment Reporting Guide (4.4.5) does speak to continue education as a way of determination of student’s enrollment status. However, this is only applicable when evaluating the end of the current school year, during the spring and summer semester, with respect to the upcoming school year’s fall semester. CAUSE University’s officials stated these students’ enrollment effective date was not reported until the last day of the semester by confirming if the student was enrolled in the next term, which resulted in reporting the incorrect date. EFFECT Failure to meet enrollment reporting requirements is noncompliance with federal regulations and could result in loss of loan/grant funding in future years. (Finding Code No. 2024-006) RECOMMENDATION We recommend the University’s registrar’s office implement processes and controls to ensure the appropriate determination of the last date of attendance for withdrawal determinations are reported to NSLDS. UNIVERSITY RESPONSE The University agrees with the recommendation.

FINDING - Noncompliance with Grant Report Requirements Federal Agency: Department of Education Assistance Listing Numbers: 84.425F Program Names and Award Numbers: Education Stabilization Fund Under the Coronavirus Aid, Relief, And Economic Security Act [COVID-19 Higher Education Emergency Relief Fund: Institution Portion (P425F200852)] Program Expenditures: $2,160,298 Questioned Costs: None Northeastern Illinois University (University) did not have adequate procedures in place to ensure the Education Stabilization Fund - Higher Education Emergency Relief Fund (HEERF) reports were accurate and timely submitted to the U.S. Department of Education and posted to the University’s website. CONDITIONS FOUND & CRITERIA During our testing of the University’s compliance with the grant reporting requirements for HEERF, we noted the University did not review the required reports to ensure accuracy and compliance with the reporting requirements of the grant agreement. We noted the following: - Four of 4 (100%) Quarterly Public Reports improperly did not report the cumulative student aid disbursed for each undergraduate and graduate student. The Department of Education Quarterly Budget and Expenditure Reporting Form requires the posting of cumulative student aid disbursed by quarter for both undergraduate and graduate. - Two of 4 (50%) Quarterly Public Reports were posted 175 days and 84 days late to the University’s website. The Department of Education Quarterly Budget and Expenditure Reporting Form requires the University to post the Quarterly Public Reports covering each quarterly reporting period (September 30, December 31, March 31, June 30), no later than 10 days after the end of each calendar quarter. Uniform Guidance (2 CFR 200.303(a)) requires nonfederal entities receiving federal awards to establish and maintain effective internal control designed to reasonably ensure compliance with Federal laws, statutes, regulations, and the terms and conditions of the Federal award. CAUSE University officials stated required reports were not timely and accurately submitted due to turnover within the University resulting in staffing constraint. EFFECT Failure to meet grant reporting requirements is noncompliance with federal regulations and could result in loss of grant funding in future years. (Finding Code No. 2024-007, 2023-007, 2022-005, 2021-008, 2020-011) RECOMMENDATION We recommend the University improve its grant reporting and monitoring process to adhere with grant requests for reporting utilizing a calendar schedule and proper review before submission. UNIVERSITY RESPONSE The University agrees with the recommendation.